UK Stewardship Code Disclosure Statement

Under COBS 2.2.3R of the FCA Handbook we are required to make a public disclosure in relation to the nature of our commitment to the UK Financial Reporting Council’s Stewardship Code (“the Code”), published in July 2010, and updated in September 2012.

The Code was published by the FRC, the United Kingdom’s independent regulator responsible for promoting high quality corporate governance and reporting in order to foster investment. The Code is directed at asset owners and asset managers with equity holdings in UK-listed companies and aims to enhance the quality of engagement between institutional investors and companies they invest in. Engagement includes pursuing purposeful dialogue on strategy, performance and the management of risk, as well as on issues that are the immediate subject of votes at general meetings.

Tideway supports the principles underlying the Code and believes firmly in the importance of corporate governance driven by strong boards and executive leadership and sound governance policies that protect and enhance long term shareholder value. Where appropriate, we seek to engage effectively with the managements of firms we invest in to understand better the potential risks and returns in order to achieve optimum returns for our clients. We have set out below the approach taken to the Code principles and explained the approach taken where we consider it not appropriate or proportionate to our business. We follow this approach for all our clients, but do not, however, apply the Principles to other asset classes in which we invest, as we do not consider it appropriate.

Our holdings in investee companies will be small typically less than 1% and thus many of the Principles will not be applied on grounds that they are not proportionate to our size of institution.

We will seek to review this statement on an annual basis, and update this where necessary to reflect changes in actual practice. Where we do this, we will inform the FRC appropriately.